I have recently joined Grant Thornton's "Tax Investigations" specialist national team, to develop a tax professional career in practice.

I am an experienced "Investigator" who spent over 10 years working at HM Revenue & Customs (HMRC) in London. I have worked in a number of different Enforcement and Compliance directorates, where I developed an excellent 'operational' skillset working in the main on numerous in-depth COP8 & COP9 investigations and Liechtenstein Disclosure Facility (LDF) / "offshore" tax disclosures.

I worked in Local Compliance's Large & Complex (now Mid-Sized Business). I risk assessed and identified cases into which enquiries were opened, and managed complex enquiries into the affairs of various client types, ie individuals (primarily High Net Worth Individuals), partnerships, family owned businesses/companies and larger corporates/groups, as well as trusts and trust-like holding structures and entities involved in wealth management. Those enquiries were generally carried out under Section 9A TMA 1970 (personal income tax self-assessment returns), Paragraph 24 Schedule 18 FA 1998 (corporate tax self-assessment returns), and Sections 12AC and 12AC(6) TMA 1970 (partnership tax returns).

I worked in Specialist Investigations' Fraud & Bespoke Avoidance for many years, specialising in risk assessing tax returns, third party information and using bulk data, to identify risks and prepare "in-depth" investigations where large amounts of tax were considered to be at risk and/or there were suspicions of fraud/evasion. I fully understand the level of pre-registration work that goes into an investigation before a client even receives a letter. I know particularly well how investigators identify third party sources of information and carry out their detailed investigations, which can be particularly 'intrusive' especially where clients are not appropriately represented by experienced professional representatives.

I am experienced in: working on Large Business' High Risk Corporates Program cases, where HMRC take a cross-directorate approach to managing an array of potential corporation tax risks; and conducting/managing investigations into Avoidance schemes where there are usually many end users.

I am well versed in the preparation, scrutinising and delivery of formal Information Notices prepared under Schedule 36 FA 2008, whether they target clients/first parties or third parties/those related or associated to the clients. I also understand the process and rationale for targeting whole groups where the identities of a class of people is typically unknown; and similarly group requests under Schedule 23 FA 2011 gathering bulk data to perform risk assessments which can lead to campaigns, taskforces and trigger other compliance activities.

As Team Leader of the specialist LDF Team in London's Specialist Investigations Offshore Group I have significant operational experience dealing with "offshore" tax matters, and have facilitated

and risk assessed several hundred personal tax disclosures. I understand what and why HMRC look for and appreciate the comfort an experienced professional adviser gives a client enabling the disclosure process to run as smoothly as possible. I created and developed the team and helped bed-in the unique bespoke advisory service offered to that office's portfolio of advisers, to allow for "no-names discussions" and achieve the greatest level of certainty for clients before their disclosures are submitted and in most cases even before they registered their intention to make a disclosure.

Following success as the Team Leader I joined the then newly created Offshore Evasion Strategy and Policy team in Whitehall, where I focussed on the Government's strategic objectives and policy projects. I was Policy Lead for the measure: Strengthening Civil Sanctions and Deterrents (Tackling Offshore Tax Evasion). My consultation document was published in August 2014, following which my summary of responses document was published at Autumn Statement 2014 along with draft primary and secondary legislation and other fiscal event products. Among other projects, I was involved in considering how HMRC could develop new streams of offshore intelligence through innovative use of information powers, data-gathering powers and Anti-Money Laundering regulations; and I created the first and only bespoke Offshore Evasion Awareness learning package for operational staff across HMRC to raise capabilities.

I am well placed to advise clients - about the significant and increasing risk of being caught by HMRC's risking activities and now considerably larger offshore teams - with potentially taxable affairs and/or offshore assets. In most cases clients will not have appreciated or considered the reasons behind HMRC contacting (prompting) them or why they should contact HMRC voluntarily before being prompted to do so. I understand what HMRC's operational teams' structures mean for clients and advisers and appreciate the drivers and capabilities of those teams.

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